Deloitte Belgium Policies

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Anti-corruption Policy

1. Definitions

In the context of this policy the following terms are understood to mean:

Corruption: offering, promising or assigning any illicit benefit or requesting or accepting any illicit benefit with the aim of being awarded a contract or an assignment.

The illicit benefit is offered/promised/assigned to or requested/accepted by:

a person acting in an official capacity;

a politician, a political candidate or a political party;

any other person in relation to his/her professional activity or based on a mandate which he/she performs.

Deloitte Belgium: all legal entities of Deloitte set up on Belgian territory.

Staff: all persons committed by means of a contract to one of the abovementioned legal entities as a director, senior manager, manager, senior or junior.

2. Statement of principles

Deloitte Belgium is committed to working in an ethical, lawful, and professional manner. Deloitte Belgium takes a clear stand in the fight against corruption: no forms of corruption whatsoever will be tolerated. Therefore, Deloitte Belgium, its partners and staff will be guided by the following principles:

No bribes are offered to win contracts.

No bribes are accepted from potential suppliers or from other companies which wish to collaborate with Deloitte Belgium.

At no time at all may the impression be given that bribes would be accepted.

This position is not only determined by the fact that corruption is a crime which is heavily punished in Belgium. Corruption is a practice that cannot be associated with a respectable business, if only to avoid the damage which may be caused by being associated with corrupt practices. Corruption also harms both the economy and society as a whole: corruption disrupts free and fair competition and promotes individual interest to the detriment of the general interest.

3. Political gifts

This policy prohibits donations (financial or other) to political parties or individual politicians. Belgian law explicitly forbids legal entities to make such political donations.

In compliance with Belgian legislation Deloitte advises all its partners against making political donations (financial or other)1. The same goes for all staff providing services to the authorities in their professional capacity. For all other staff, political donations (financial or other) are a purely personal matter. Under no circumstances can such donations be recovered from Deloitte Belgium. Deloitte staff members are not allowed to use Deloitte assets/resources to support political activities or campaigns.

1 Political donations (financial or other) are understood to be, for example: making financial contributions in favor of a political party, paying a sum of money in cash to an individual politician, making boards available for election campaigns, etc.

4. Charities / Patronage / Social responsibility

Deloitte Belgium is a business that attaches great importance to corporate social responsibility. In order to comply with laws and regulations, staff members are committed to ensuring that the line between supporting charities or patronage and concealing forms of corruption is thoroughly guarded.

5. Gifts and hospitality

Offering gifts or hospitality is allowed under very strict conditions. Partners and staff of Deloitte Belgium are not allowed to offer gifts or hospitality with the intention of securing contracts or assignments. The same applies to the acceptance of gifts or hospitality by Deloitte partners or staff. Hospitality or gifts can be awarded or accepted, under the condition that they remain within the bounds of reasonableness.

6. Facilitation payments

In certain countries, one can be confronted with requests from an official to pay a (usually small) amount of money for a certain action, while one knows or suspects that no payment is actually required for that action. This policy requires Deloitte staff to avoid any activity that might lead to, or suggest, that a facilitation payment will be made or accepted.

7. Providing free services or services at a strongly reduced price

Deloitte staff and partners are prohibited from using their position within Deloitte Belgium to provide free services or services at a strongly reduced price if this is accompanied with the expectation that, in exchange for free services or services at a reduced price, the receiving party will exert his/her influence to award a contract or assignment to Deloitte Belgium.

8. Hiring

Deloitte Belgium will not attempt to obtain or retain business or to secure an improper advantage of any kind by offering or providing any employment (including temporary employment or an internship) to any candidate (1) who is an existing or prospective client; (2) who is a government/public official; (3) who is related to or closely affiliated with an existing or prospective client or government/public official; or (4) who has been referred to Deloitte Belgium directly or indirectly by an existing or prospective client or government/public official.

9. Staff responsibility

As a company we take our responsibilities seriously, including the responsibility to prevent corruption by our staff. We give our staff the responsibility to familiarise themselves and comply with Deloitte Belgium’s internal anti-corruption policy. All Deloitte staff members are genuinely committed to our shared objective of doing business the right way.

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